Troutman Sanders
October 7, 2009
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IRS Guidance On Loan Origination By Foreign Entities
IRS Issues Guidance on When Lending Activity By An A Non-U.S. Person May Subject It To U.S. Income Taxation
Loans by Offshore Entities to US Borrowers May Constitute Effectively Connected Income
Arnold & Porter
October 6, 2009
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Offshore funds engaged in U.S. trade or business
Freshfields Bruckhaus Deringer
October 2, 2009
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IRS Concludes That Foreign Lender Conducts a U.S Trade or Business
King & Spalding
October 2, 2009
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IRS Ruling Guidance on Lending Activities of Foreign Entities is a “Shot Across the Bow”
Milbank
September 25, 2009
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IRS Scrutinizes Offshore Hedge Fund Lending
Kilpatrick Stockton
September 30, 2009
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IRS Draws Battle Lines in Examinations of Foreign Lenders Using Third-Party Originators
Patton Boggs
September 29, 2009
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IRS Chief Counsel advises field operations on loan origination by foreign entities through U.S. representatives
Dechert
September 2009
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Lending activity by offshore foreign corporation gives rise to effectively connected income according to Internal Revenue Service Memorandum
DLA Piper
September 23, 2009
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